Mar 26, 2024 IPAA Comments on Inflation Reduction Act – Waste Emissions Charge Proposal
The Independent Petroleum Association of America (IPAA) submits these comments regarding the Environmental Protection Agency (EPA) proposal to implement a Waste Emissions Charge for Petroleum and Natural Gas Systems (WEC) under the Inflation Reduction Act Methane Emissions Reduction Program (Methane Tax).
In addition to the comments filed here, unless there are specific comments presented herein, IPAA endorses the comments filed by the American Petroleum Institute (API).
The Methane Tax process includes multiple features. However, a key factor in conjunction with this WEC proposal is the application of information from Subpart W. IPAA previously filed comments on the EPA proposal to modify Subpart W (EPA-HQ-OAR-2023-0234-0265). These comments are included in this submission as Appendix A.
Because the emissions calculations under Subpart W are the building blocks for calculation of the WEC, these comments will reiterate and expand on those prior comments. Then, it will address key issues in the WEC proposal.
